You are using an outdated browser and your browsing experience will not be optimal. Please update to the latest version of Microsoft Edge, Google Chrome or Mozilla Firefox. Install Microsoft Edge

April 9, 2022

Myanmar Clarifies Foreign Currency Conversion Requirements

Subscribe to Updates

Following Myanmar’s recently announced notification requiring conversion of all foreign currency transfers and balances to Myanmar kyat (MMK), the Central Bank of Myanmar (CBM) has issued additional detailed guidance to banks on how to manage transfers, outbound remittances, and various other transactions involving balances in foreign currency. The CBM also announced that the union government and ministries are exempt from the foreign currency conversion requirements.

The developments came on April 5, 2022, when the CBM issued Directive No. 5/2022, exempting these government bodies from the requirement, and Directive No. 6/2022, which provides instructions for banks licensed as authorized dealers (ADs) permitted to exchange currencies. The directive makes AD-licensed banks responsible for handling the conversion process by (1) transferring the amount in question to the concerned company’s account, (2) converting the amount to MMK at the CBM exchange rate, and (3) depositing it in an MMK-denominated account. The conversion process must be carried out within one working day of receiving the following types of funds:

  • Export earnings
  • Other earnings (including from services)
  • Foreign currency investments (excluding foreign currency allowed by the CBM’s Foreign Currency Management Committee)

The conversion process is also required for the following two types of funds, which require the AD-licensed bank to perform additional checks:

  • Loans for investment. AD-licensed banks may only proceed with the conversion process after determining that CBM approval has been obtained in accordance with section 29(a) of the Foreign Currency Management Law and Rule 48 of the Foreign Currency Management Rules.
  • Unilateral transactions. AD-licensed banks may only proceed with the conversion process after determining that CBM approval has been obtained in accordance with the rules 54 and 55 of the Foreign Exchange Management Rules.

As noted in the previous notification instituting the foreign exchange requirements, outbound transfers of foreign currency by resident individuals and entities in Myanmar are to be carried out with the permission of CBM’s Foreign Exchange Supervisory Committee. Directive No. 6/2022 stipulates that this includes (but is not limited to) the following:

  • Payment for imports (including advance payments)
  • Payment for service fees and other expenses
  • Remittance of dividends accruing from foreign investment, and return of investment capital
  • Transfers for investment in foreign countries
  • Making loan and interest payments to lenders in foreign countries
  • Transferring expenses and fees as stipulated in rule 27 of the Foreign Exchange Management Rules

After obtaining the Foreign Exchange Supervisory Committee’s permission for an outbound transfer, AD-licensed banks are to sell foreign currency according to the CBM exchange rate, and can charge fees of MMK 3 per USD 1.

Related Professionals

Practices

Banking and Finance

Location

RELATED INSIGHTS​ 

February 27, 2026
The Bank of Thailand (BOT) has officially implemented a new regulatory framework supervising systemically important retail payment systems (SIRPS), effective February 21, 2026, with PromptPay being the first payment system designated as a SIRPS. Under this new set of regulations, the BOT may designate payment systems under the Payment Systems Act B.E. 2560 (2017) as SIRPSs based on quantitative and qualitative assessments. Once a system is designated as a SIRPS, the operator becomes subject to expanded supervisory obligations beyond the general requirements of the Payment Systems Act. Enhanced Supervisory Requirements SIRPS operators must comply with a heightened supervisory regime across three key areas, outlined below. 1. Governance SIRPS operators must maintain robust and transparent governance structures, including: Balanced board composition, with at least one-third of the board comprising independent directors who represent stakeholders in the system (such as payment service providers, consumers, and experts). Independent directors may serve for no more than two consecutive terms. Subcommittees to assist the board in overseeing compliance, policy implementation, and operational strategy. Clear separation between executives responsible for risk and information security and those overseeing day-to-day business operations. Risk Management and System SecuritySIRPS operators must implement comprehensive risk management frameworks, including: Clear service agreements between the SIRPS operator and its direct participants (payment service providers who connect directly to the SIRPS), defining roles and responsibilities among stakeholders. These agreements must include obligations for direct SIRPS participants to supervise any indirect participants they onboard to ensure compliance with service agreements and business rules. A business continuity plan covering both IT and non-IT aspects, with annual review. The SIRPS must target service availability comparable to international payment infrastructures, including the ability to recover operations within two hours of a disruption and to maintain scalable operational capacity. Tools and controls to monitor and manage material or
Read More
February 9, 2026
When unauthorized credit card transactions occur, who bears responsibility—the cardholder or the issuing bank? In Thailand, a landmark 2025 ruling by the country’s Supreme Court has clarified this question, establishing a stricter standard for banks in fraud disputes and significantly strengthening consumer protections. The case centered on disputed charges where a customer claimed their credit card had been used without authorization. The bank sued to recover the amount, and both the court of first instance and the Court of Appeal ruled in favor of the bank. However, the Supreme Court overruled their judgments and decided that the customer did not need to pay for the unauthorized transactions, placing liability squarely on the bank. This ruling was based on three key findings, which are outlined below. Finding 1: Insufficient Expert Testimony In this case, the bank bore the burden of proving matters related to the credit card system’s manufacture, design, security, and operation, as required under the Consumer Case Procedure Act B.E. 2551 (2008). To meet this requirement, the bank presented testimony from two employees in its credit card department regarding ’security measures and issuance procedures. However, the Supreme Court found these witnesses unqualified as experts, as they did not present technical or academic evidence and did not possess specialized expertise in credit card technology. As a result, their testimony failed to establish that the bank’s credit card technology was sufficiently secure against fraudulent misuse. Finding 2: Contradictory Terms and Conditions The bank’s own credit card terms and conditions included a provision acknowledging that despite the card’s EMV security standards, cardholders must still exercise caution to prevent unauthorized access. The Supreme Court interpreted this clause as an explicit admission that credit card systems remain vulnerable to hacking and fraud, even with high-level security measures in place. This acknowledgment undermined the
Read More
February 4, 2026
On November 18, 2025, Vietnam’s Ministry of Finance released for public consultation a draft decree on administrative sanctions in the field of crypto assets and crypto asset markets (the “Draft Decree”), intended to implement Resolution No. 05/2025/NQ-CP dated September 9, 2025, on the pilot crypto asset market in Vietnam (“Resolution 05”). While Resolution 05 sets out who may participate and under what conditions, the Draft Decree addresses a more practical question for market participants, i.e., what happens if those conditions are not met. In doing so, the Draft Decree offers important insight into how Vietnamese regulators intend to supervise, discipline, and ultimately shape the crypto market during the pilot phase. Regulatory Scope and Overall Sanctions Architecture The Draft Decree applies to both domestic and foreign organizations and individuals engaging in crypto-related activities in Vietnam’s market. Covered entities include: (i) crypto asset issuers; (ii) crypto asset service providers, including trading platforms and market operators; (iii) Vietnamese and foreign investors participating in the pilot market; and (iv) other organizations involved in the offering, issuance, or provision of crypto-related services in Vietnam. The breadth of this scope is deliberate. It appears to reflect a regulatory view that cross-border structures, offshore platforms, and indirect participation may not necessarily insulate market actors from compliance obligations once they operate within the pilot framework. For the crypto industry, this may mark a shift from regulatory ambiguity toward a more explicit articulation of jurisdictional reach. At first glance, the Draft Decree’s monetary penalties appear restrained. The maximum fine per administrative violation is capped at VND 200 million (approx. USD 7,700) for organizations and VND 100 million (approx. USD 3,800) for individuals. However, focusing solely on fine levels risks missing the point. The Draft Decree also places great regulatory weight on supplementary sanctions and corrective measures, including: (i)
Read More
January 23, 2026
On December 31, 2025, the State Bank of Vietnam (SBV) issued Circular No. 72/2025/TT-NHNN (Circular 72), establishing a streamlined foreign exchange framework for Vietnam’s International Financial Center (IFC). Circular 72, which took effect on the same day, implements core provisions of Decree No. 329/2025/ND-CP and marks a fundamental shift from ex ante licensing to ex post supervision for IFC member enterprises and foreign investors. These changes are designed to accelerate capital flows, reduce compliance costs, and position Vietnam as a competitive regional financial hub by granting IFC members substantially greater autonomy in currency transactions, borrowing, lending, and investment activities. Key provisions for IFC members to note are discussed below. Use of Foreign Currency and Payments within the IFC Vietnam generally requires the use of Vietnamese dong for transactions within the country, with limited exceptions. This can be burdensome for foreign investors, who may be unfamiliar with all the foreign exchange rules they must comply with. Under the new regulation, IFC member enterprises and foreign investors gain the ability to transact, list prices, and settle obligations in foreign currency when dealing with other IFC members or offshore counterparties, avoiding currency risk and conversion friction. With respect to individuals and organizations located within Vietnam who are not IFC members, the use of foreign currency must continue to comply with general restrictions on foreign exchange usage within Vietnam. Dual-Track Account System for IFC Members The new regulation introduces a two-tier account structure that differentiates transactions by purpose and counterparty. IFC member enterprises must use a designated foreign currency capital account at an IFC member bank for four specified activities: Borrowing from offshore individuals and organizations Lending to offshore entities and domestic borrowers Outbound investing from the IFC Investing elsewhere in Vietnam from the IFC All other foreign exchange transactions—including operational receipts, vendor
Read More